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Digital Governance, Regimes Theory and Private International Law. A tech diplomacy perspective

By Juliano Alves Pinto, Brazilian tech diplomat; former Deputy Consul of Brazil in San Francisco (2013–2016); State Undersecretary of Science, Technology, and Innovation (2019–2021); HCCH expert on digital economy (2023–2024); and Government Affairs Director at the Digital Cooperation Organization (DCO) (2024–2025)

Could Private International Law be an answer to digital governance? Though this idea has already been debated among PIL scholars, it must be said that it has not yet broken the bubble of the PIL niche. Diplomats usually overlook PIL as a small part of the larger International Law realm, which embraces Public International Law as the standard bearer of the multilateral framework that has been established ever since the Westphalia Peace in 1648. Read more

Tatlici v. Tatlici on Appeal: Defendant Wins as Public Policy Confronts the Financialization of Cross-Border Defamation Award

Written by Fikri Soral, Independant Lawyer, Turkey; and LL.M. student, Galatasaray University, Turkey

The Tatlici litigation continues to unfold as one of the most noteworthy examples of how national courts in Europe are responding to transnational defamation judgments obtained in the United States. The previous commentary examined Malta’s First Hall Civil Court judgment refusing to enforce the U.S. default award of US$740 million.[1] The Malta Court of Appeal’s judgment of 14 October 2025 builds upon that foundation by upholding non-enforcement while clarifying the legal reasoning behind it.[2] The Malta Court of Appeal’s judgment came as the second major development, following an earlier first-round enforcement attempt in Turkey that had already failed on venue.[3] Read more

‘Paramount clause’ in a bill of lading as choice of law under Rome I – the Supreme Court of the Netherlands in Airgas USA v Universal Africa Lines

In Airgas USA v Universal Africa Lines (7/11/2025, ECLI:NL:HR:2025:1665), the Supreme Court of the Netherlands considered the interpretation of a so-called ‘Paramount clause’ in a bill of lading. Such clauses commonly signpost which rules govern the international carriage of goods by sea. The Court addressed such clause as a choice of law and held that article 3(1) of the Rome I Regulation does not preclude the parties from agreeing on such clause. Read more

News

Perspectives contentieuses internationales (PCI), Volume 5

The following announcement was kindly shared with us by Fabienne Jault-Seseke

The 5th issue of Perspectives contentieuses internationales is online.

logo PCI

It is a special issue devoted to a dossier entitled “The Exploitation of Natural Resources in the Face of the Energy Transition,” prepared under the direction of RebeccaLegendre and Denys-Sacha Robin. It provides an opportunity to reflect on the transformations that the extractive sector as a whole is facing as a result of sustainable development policies, as well as on the multiple disputes likely to arise from the difficult reconciliation of competing considerations. Read more

Revue critique de droit international privé – Issue 2026/1

Written by Hadrien Pauchard (assistant researcher and doctoral student at Sciences Po Law School)

The first issue of the Revue Critique de droit international privé of 2026 has just come off the press and is available online. It contains three articles, nine case notes, and eight book reviews. In line with the Revue Critique’s recent policy, the doctrinal part will soon be made available in English on the editor’s website (for registered users and institutions).
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Foreign Judgment Enforcement: Zimbabwean High Court holds that a Confirmed Mareva Injunction is a Final Judgment

In the Zimbabwe High Court decision of  Ser and Another v Yong and Another (92 of 2026; HC/SUM 1957/2025) [2026] ZWHHC 137 (8 April 2026), the applicant obtained a freezing (Mareva) injunction from a foreign court in Singapore against assets linked to the respondents and then sought to have that order registered and enforced in Zimbabwe. The respondents resisted enforcement, arguing that the order should not be recognised because it was interlocutory in nature and because a relevant foreign defendant had not been joined to the original proceedings. The dispute therefore arose in the context of an attempt to extend the effect of a foreign asset-preservation order into Zimbabwe against parties and assets within its jurisdiction.

In the words of Wamambo J,
“In the present case, the judgment of the 19th of December 2025 is a product of detailed submissions by the parties on the merits of the injunction and is final and definitive in as far as that subject matter relates to the parties herein, who were the protagonists in the Singapore High Court. Whilst the order of 21 July was a temporary injunction, which was the subject of either confirmation or discharge, it has since been confirmed by the judgment of 19 December 2025, and has thus become what is commonly known as a final injunction as it no longer has any return date and is no longer in jeopardy of cancellation at the instance of the respondents as it was prior to 19 December 2025.”

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